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#2090131 - 07/27/16 03:30 PM Re: Can an FDIC regulated bank sell raffle tickets? Andy_Z
M Cockrell Offline
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Sorry. I missed Andy's response, while typing my own.
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#2090133 - 07/27/16 03:31 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
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Fed rules are similar:

Federal Reserve Act

Section 9A. Participation in lotteries prohibited
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#2090139 - 07/27/16 03:36 PM Re: Can an FDIC regulated bank sell raffle tickets? M Cockrell
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Quote:
...are we prohibited from displaying them in one of our lobbies?


No.
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#2090172 - 07/27/16 05:00 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
M Cockrell Offline
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Thank you Andy, Randy & Ken.
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#2093318 - 08/15/16 07:33 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
SonnyGirl Offline
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Bringing this Thread back up. The exception Andy references:

"There is one "new" exception to the lottery rule but it is meant to promote savings deposit growth and to my knowledge has been used very little by banks. It would not apply to this case. "

Does this allow, for example, a promotion in a school where we would be offering savings accounts and students who open one would be included in a drawing for an iPad? We could restrict it to those and not provide other students the opportunity to be in the drawing for the iPad? It sounds that way but not sure. I have tried to find any background information or discussion on the exception; no luck so far.

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#2093333 - 08/15/16 08:01 PM Re: Can an FDIC regulated bank sell raffle tickets? SonnyGirl
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Andy's comment may have been in reference to prized-linked savings accounts.
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#2176547 - 05/03/18 06:00 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
Beachbum, CRCM Offline
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I am resurrecting this thread to ask about the savings promotional raffles.
I understand there is an exception to the lottery rule for raffles that promote the deposit into a savings account. For these raffles the bank can predetermine the qualifying dollar amount to be deposited for entry into the raffle. My question is- can the bank restrict the entry into the raffle to new savings accounts only?

Federal Reserve Act, Section 9A(c)4

The term "savings promotion raffle" means a contest in which the sole consideration required for a chance of
winning designated prizes is obtained by the deposit of a specified amount of money in a savings account or other
savings program, where each ticket or entry has an equal chance of being drawn, such contest being subject to
regulations that may from time to time be promulgated by the appropriate prudential regulator (as defined in section
1002 of the Consumer Financial Protection Act of 2010 (12 U.S.C. 5481)).
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#2176551 - 05/03/18 06:12 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
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First question is whether they are legal in your State? Most States would have been required to pass State legislation to allow for such to avoid violating State lottery laws. You will most likely find you answer there.
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#2176554 - 05/03/18 06:21 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
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Also, since you are limited to "sole consideration required for a chance of winning designated prizes is obtained by the deposit of a specified amount of money in a savings account or other savings program" I don't think you can tie it also to having to open an account.
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#2177847 - 05/11/18 04:09 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
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Your cite is quoting the American Savings Promotion Act. It's intent is to allow an exception to the prohibitive laws and allow this raffle to bolster savings deposits. The ASP doesn't define much and there is no implementing regulation or guidance that I am aware of. The ASP requires deposit into a savings account, or a savings program. It doesn't say if a CD is acceptable, or an MMDA or a NOW, or if we use the 7-day notice rule to consider a savings, or what a savings program is.

Requiring the funds into a savings at your bank seems to hold with the spirit and intent, but there is no guidance. And if you required it be at your bank, how long can that requirement hold, or can the depositor withdraw and use the funds next week, next month, next year? The bank has no control once the funds are withdrawn and when the owner wants the funds, I would thing the most the bank could do would be to enforce it's contract, the 7 day notice period, which is ignored 99.999% of the time or 100% in most cases.
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#2177853 - 05/11/18 04:22 PM Re: Can an FDIC regulated bank sell raffle tickets? Gandalf
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FWIW, it isn't on the training calendar yet but I'll cover some of this in a webinar on Contests, on June 13.
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